Instreamatic, Inc. (“Instreamatic,” “we”, or “us”) offers technology and services to its clients that enable them to interact with their audience by providing a platform for its audience to provide voice-based feedback. One of these services is Voice Feedback, which we refer to as the “Platform” in this Policy. References to “you” or your” in this Policy are to the individual who is using the Platform to provide information to or communicate with our client.
This Policy covers data we collect for the purpose of delivering and enhancing our services to you through the Platform. We are committed to protecting consumer privacy by informing you of what information we collect, how we use it, and with whom we may share it. We adhere to the Privacy Principles adopted by the Interactive Advertising Bureau (IAB).
Personal Information We Collect
The definitions of “personal data” vary depending on the laws where you are located. For example, in the European Union (EU), Canada and the U.S. State of California, personal data is defined more broadly than in other places and includes both “personally identifiable information” (such as an individual’s name, age, gender, residence, email address, or phone number) and “pseudonymous identifiers” (which are discussed below). In California, PII and pseudonymous identifiers are sometimes referred to as “personal information.” However, to make our Policy clearer to you, we are using the term “personally identifiable information” or “PII” in this Policy to mean information that specifically identifies you as an individual and “pseudonymous identifiers” as a separate category of information.
Instreamatic does not knowingly collect personally identifiable information through the Platform from our clients or from our clients’ customers or store that information. It is possible that a customer of a client may provide PII in a voice recording the customer makes when using the Platform. We do not process that PII nor make it available to any person other than the client or as may need to be disclosed by law or court order as further described in Disclosure of Data below.
We do access, collect and process pseudonymous identifiers via the Platform. A pseudonymous identifier is data that helps our Platform recognize a particular browser or device and certain information about the person who is using the platform, but it doesn’t enable us to know the user’s identity as a natural person. For example, we collect voice data from which your age, gender and your level of engagement with a product or service you are requesting may be deduced, but we do not attempt to use pseudonymous identifiers we collect to identify who you are as an individual. Rather, the information collected helps us to better understand your interests and preferences. We may also obtain pseudonymous identifiers from third party data vendors that receive such information pursuant to their own privacy policies.
The information we may collect from you is:
- The browser identifier of your device or cookie installed when you access the Platform (see below for more information on cookies);
- The IP Address of your device;
- Your device’s operating system and its version;
- The device type you are using;
- Audio-recordings of your responses to Voice Feedback and the text-version of the audio-recordings. These recordings are either kept anonymously or in relation to a specific IP address or browser identifier.
As mentioned, we do not intentionally collect personally identifiable information via our advertising technology. The information we collect by providing our services is meant to be traced back to an unidentified individual only for the purposes of the voice interaction and possibly for related transactions with the user.
We do not intentionally or knowingly collect information from children under 16 years of age, and we do not tailor any segments to children under 16 years of age.
How We Use Information We Collect
We process voice and other data to enable user interaction with the Platform Such voice data is retained for an appropriate amount of time for the processing of the requested transactions and any further period for purposes of the transaction and maintaining a legal record of the transactions.
We also use the data we collect to maintain and improve the Platform and to develop new services.
We also may sell information we collect through Voice Feedback to our clients and other third parties for their use in marketing goods and services. We do not sell or otherwise market a customer’s PII that we may collect, however. You may opt out of allowing us to sell your personal information (including information that consists of pseudonymized identifiers) we collect related to your interactions on Voice Feedback. See Right to Opt-Out of Sale of Data for how to opt out of permitting us to sell your personal information.
We retain some of the information we collect, such as voice interactions with our Platform both in audio recording and text formats as well as the related IP address or IDFA/GAID identifier. We retain such recordings and texts for a maximum of 24 months, on a rolling basis, and we do so only as necessary in relation to the purpose for which we collect data (see above for the purpose for which we collect such information).
Security of Data
We take reasonable and appropriate measures to ensure that all data is kept secure including measures to prevent personal data from being accidentally lost, misused or accessed without authorization. This includes but is not limited to the use of firewalls and encryption. No method of transmission over the Internet or method of electronic storage is 100% secure; therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach when we are legally required to do so.
Opting Out of Data Collection
If you prefer not to receive targeted advertising from us, you can opt-out of our processing of data by the Platform by clicking on this link https://tech.instreamatic.com/remove-your-data-opt-out/or by opting out using the controls given to you by the application from which you accessed the Platform or by opting out on the device on which our Platform is used. In addition, where we receive an individual’s request to opt-out of targeted advertising from a Client we will apply that opt-out request to our Platform as well. However you opt-out, we will set a cookie on your browser that tells us not to collect information from you and not to tailor ads to your interests. Opting out does not mean you will not be served an ad by us, but that the ads we serve will be less relevant to your interests. Please note that the opt-out cookie only applies to the mobile device or computer and browser where it is set. If you delete the opt-out cookie (such as by clearing all cookies on your browser), you will need to renew your opt-out choice. Please note that the opt-out process may be different for each mobile operating system.
Disclosure of Data
We are occasionally asked by our clients to provide information regarding our services including information concerning the effectiveness of ads run on the Platform. When we provide such information, we do so only on an anonymous basis or through pseudonymous identifiers.
Please note that we may disclose information to third parties when obligated to do so by law, to investigate, prevent, or take action regarding suspected or actual prohibited activities, to meet national security or law enforcement requirements, or when we believe in good faith that disclosure is necessary to protect our rights, including but not limited to fraud and situations involving potential threats to the physical safety of any person. In the event that we sell, merge or transfer all or part of our business, we may transfer personal information to a third party as part of that transaction.
Removing, Accessing, and Correcting Information
Right to Remove Personal Information — Right To Be Forgotten
You have a right under the CCPA and the GDPR to have us remove your personal information that we possess. Under the GDPR this is referred to as the “Right to be Forgotten.”
You may ask that we remove your personal information by clicking on this link: https://tech.instreamatic.com/remove-your-data-opt-out/, and completing the information on that page. You may also make a request for us to remove your personal information by e-mailing us at email@example.com with your full name, your email address, and your IDFA (Apple Ad ID) or Google Advertising ID (GAID – Android) with a request to remove your data. We will confirm your request within 10 days of receiving your verified request and proceed to remove your personal information we have within 45 days of receiving that request.
There are certain circumstances in which we are not required to remove personal information about you under the CCPA or GDPR. In addition, the GDPR imposes different requirements than those in the CCPA about what information we are required to remove. For example, under the CCPA, we are only required to remove personal information that we obtained from you in your interactions with the Platform, which means that we may retain your personal information that we may receive from third parties or that we develop on our own. By contrast, under the GDPR we may be required to remove personal information about you regardless of how we obtained it. Our decision as to which personal information we will remove will be based in part on whether the CCPA or GDPR applies to your personal information. We will notify you of the grounds we have for not removing your personal information if we conclude that we are not required to or cannot comply with your request to remove personal information.
Right to Know
The CCPA and GDPR provide you with the right to know what personal information we have concerning you. The information you have a right to receive from us are: (1) The categories of personal information we have collected about you; (2) the categories of sources from which we obtained this information; (3) our business purpose for collecting, selling, or sharing this personal information; (4) the categories of third parties to whom the business discloses personal information; (5) the specific pieces of personal information we have collected about you; and (6) the categories of personal information that we have sold and the categories of third parties to whom we have sold that information. The information we provide will be that which come within these categories that we have collected and retained over the previous 12 months from the date of your request.
If you would like to know what personal information we have about you, then email us at firstname.lastname@example.org with your full name, your email address, and your IDFA (Apple Ad ID) or Google Advertising ID (GAID – Android) with a request to know what information we have about you. We will confirm your request within 10 days and make a good faith attempt to fulfill your request within 45 days.
Right to Opt-Out of Selling Information
You may opt out of allowing us to sell personal information we collect about you and your interactions on Voice Feedback by clicking on the following link: https://tech.instreamatic.com/remove-your-data-opt-out or by sending us an e-mail at email@example.com. See “How We Use Information We Collect” for a further discussion of what personal information we may sell to third parties.
Right to Correction of Information
Depending on your location (e.g., you are resident in California or the EU) you have the right to have us correct any mistakes in your information that we possess. Please contact us at firstname.lastname@example.org if you would like to request us to correct any of your personal information that we possess.
Right to Nondiscrimination
You have a right not to be discriminated against if you exercise any of the rights described above to remove your personal information, know what of your personal information we possess and sell, opt-out of selling your personal information, and to correct your personal information we possess. Specifically, we will not deny you access to the Voice Feedback Platform, cause it to operate more slowly or otherwise with a lower level of quality, or operate without features made available to others if you choose to exercise these rights. We may, however, offer payments or other financial incentives to users who expressly agree to allow us to use, process, and/or sell their personal financial information.
You may have an authorized agent remove, access or change information pursuant to the instructions above. Please make sure to authorize only someone you trust to act as your authorized agent. We are not responsible for actions taken by your agent.
Compliance with GDPR Article 6
Pursuant to the GDPR, where we are a controller of data, the legal basis for our collection of data will have both a legitimate interest and with consent in accordance with Article 6 of the GDPR. The processing of your data is not high risk and will not violate fundamental human rights. We process personal data of Clients for the performance of our contracts with them in accordance with Article 6 of the GDPR.
3101 Park Blvd.
Palo Alto, CA 94306
This Policy was last updated on: January 10, 2022